Bulletin puts national banks on notice about revised exam practices under TILA

Revised interagency examination procedures for the Truth in Lending Act (TILA), implemented by Regulation Z, are outlined in a bulletin issued Wednesday by the regulator of national banks.

The Office of the Comptroller of the Currency (OCC) said the revised exam practices were adopted by the Federal Financial Institutions Examinations Council (FFIEC). They reflect amendments to Reg Z published through May 18, 2018.

According to the OCC, the FFIEC developed the procedures to “promote consistency in the examination process and communication of supervisory expectations.” Among other things, the OCC said the procedures:

  • Reflect amendments to Reg Z that relate to the TILA-RESPA Integrated Mortgage Disclosure Rule.
  • Mirror provisions to TILA relating to the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) of 2018. Those include:
    • provisions relating to high-cost loans, appraisals, and student lending;
    • an additional type of qualified mortgage for insured depository institutions with less than $10 billion in assets;
    • an additional type of escrow exemption for insured depository institutions with less than $10 billion in assets.

OCC Bulletin 2020-84: Truth in Lending Act: Revised Interagency Examination Procedures